p120557.eng

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0557

Focus Ready Draft 1/3/2013

ENGINEER: Austin \ JAS

PV (kg/yr): 1,635,598 YX

SUBMITTER: Green Carbon

USE: Feedstock for oil refining.

OTHER USES: Analog is used as a fuel for

industrial boilers, a marine fuel for ocean going vessels,

 a solvent used as industrial degreaser or dissolving

agent used in aiding chemical reactions for manufacturing

purposes, and an oil extender used in custom blending of

oils. Analog is used as a cutter stock for Fuel

Oil No.6 for industrial boilers of for marine diesel oil

for marine engines. Analog is used as a

gasification feedstock for producing CO and H2, as a

feedstock to be distilled for petroeleum products, and to

generate clean energy from waste tires.

MSDS: Yes Label: No

Gen Eqpt: impervious gloves are recommended / wear

chemical safety glasses/ mechanical ventilation such as

local exhaust as required to minimize exposure levels.

Use explosion-proof equipment as required.

Respirator: For operations where the occupational

exposure limit may be exceeded or exposures are excessive,

 a NIOSH approved organic vapor respirator with organic

vapor cartridges with dust/mist pre-filters or supplied

air respirator is recommended. Equipment selection

depends on contaminant type and concentration, select in

accordance with OSHA 1910.134, ANSI Z88.2, and good

industrial hygiene practice.

Health Effects: Flammable liquid and vapor. Causes skin

and eye irritation. May be absorbed through the skin in

harmful amounts. Repeated skin exposure may cause dryness

or cracking. Inhalation may cause irritation, headache,

dizziness, and drowsiness. Harmful or fatal if swallowed.

Contains chemicals that may cause cancer.

TLV/PEL:

TVR Oil (PMN) 100 % 5 mg/m3 TWA OSHA PEL (as mineral oil

dust)

CRSS :

Chemical Name: 

S-H20: g/L @

VP: 1.7E+2 torr @

MW: 78.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: Liquid Proc/Form: Solution: <1% PMN

material in naphtha, kerosene, diesel fuel, and gasoline

End Use: Destroyed. The structures shown on page 1 of

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this report are representative. The submiter provided

analyses of two samples of the PMN material, showing

product distributions of

 The

molecular weight shown above is for the low weight

component . Submitted Properties: BP = 66-510 ¦C;

VP = 0.3 torr (Sub. Est.); Density = 0.9 g/cc; Viscosity

= 3.48 cSt; Flash Point = 88 ¦F (Sub. Est.). Properties

for : MP = -153.7 ¦C (PhysProp); BP = 60.

2 ¦C (PhysProp); VP = 211 torr (PhysProp); WS = 0.014 g/L

(PhysProp); logP = 3.21 (EPI). Properties for

methylcyclopentane: MP = -142.5 ¦C (PhysProp); BP = 71.8

¦C (PhysProp); VP = 1385 torr (PhysProp); WS = 0.042 g/L

(PhysProp); logP = 3.37 (PhysProp). Continued on

page 6 of this report.

Consumer Use: No

SAT (concerns) (12/21/2012):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Related Cases: 

Migration to groundwater: negl-mod

PBT rating: P3B3T1 P Rating: 1-3 // B Rating: 1-3

Health: 1-2 Dermal, Inhalation

Eco: 2 Water (All releases to water with a CC = 360 ppb.)

OCCUPATIONAL EXPOSURE RATING: 2-3C

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: Yes (2 criteria met)

1) # of workers exposed: 126 >1000? No

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2) >100 workers with >10 mg/day inhalation exposure: Yes

3) (a) >100 workers w/1-10 mg/day inh. exp. & >100

days/yr: No

 (b) Routine Dermal Cont: >250 workers & >100 days/yr:

Yes

INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 12-0557

Manufacturing: Batch

Number of Sites/ Location: 

 

 

Process Description: Rubber tire feedstock added to

reactor --> Reactor is heated to 750 degrees and F -->

Gas vapors are pulled from the reactor under vacuum -->

Vapors are condensed in two streams (heavy oild and light

oil) --> The heavy and liight oils are stored in separate

2000-5000 gallon tanks --> PMN (heavy and light oils),

100%) is pumped into 5000 gal tanker trucks (submission).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water

Central Tendency: 7.7E-1 kg/site-day over 1 day/yr from 6

sites

to:

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB

standard 1% residual. Spoke with submitter, vapor build

up cleaned one per year.

Air

Typical: 7.7E-1 kg/site-day over 248 days/yr from 6 sites

Worst Case: 7.7E-1 kg/site-day over 248 days/yr from 6

sites

to: not assessed

from: Loading Liquid Product into Tank Trucks

basis: EPA/OAQPS AP-42 Loading Model. Note that this

model is presented to calculate a vapor generation rate

that is used for the inhalation exposure model. Air

releases based on submitter information is used as more

conservative. Also note that the VP for this PMN (168

torr) falls outside of the recommended vapor pressure

range of 0.001-35 torr for this model.

Air

Output 2: 2.0E+0 kg/site-day over 248 days/yr from 6 sites

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to: air

from: Loading Liquid Product into Tank Trucks

basis: User-Defined Loss Rate Model. The submission

estimates 1 kg/batch is released to fugitive air during

light oil processing and 1 kg/batch is released to stack

air during storage and loading. The submisison also

indicates that testing indicates that no flue gas

scrubber or thermal oxidizer is required to meet

emissions limits; therefore CEB assesses 100% of these

releases directly to air. Note that these estimates are

more conservative than the AP-42 loading model, which

assesses release of 0.8 kg/site-day.

RELEASE TOTAL

5.3E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 6

Basis:

Inhalation:

Exposure to Vapor (Class II)

Typical: 3.7E+2 mg/day over 248 days/yr

Worst Case: 1.1E+4 mg/day over 248 days/yr

Number of workers (all sites) with inhalation exposure: 6

Basis: Loading Liquid Product into Tank Trucks; EPA/OPPT

Mass Balance Model. Note that the VP for this PMN (168

torr) falls outside of the recommended vapor pressure

range of 0.001-35 torr for this model. This model is

presented as a conservative estimate.

NOTE: The respirator class is: II. Gas/vapor (all

substances in the gas form).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 248 days/yr

Number of workers (all sites) with dermal exposure: 6

Basis: Loading Liquid Product into Tank Trucks; EPA/OPPT

2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0557

Processing: Oil Blending

Number of Sites/ Location: 

 

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Process Description: PMN (liquid, 100%) in tank trucks

--> PMN blended with other recycled oils --> Filtration

--> Loading (liquid, <1%) (per submission).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water

High End: 4.5E-1 kg/site-day over 4 days/yr from 20 sites

to:

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB

standard 1% residual. Spoke with submitter, process fuel

blends cleans single gracity drained tank quarterly.

Water or Incineration or Landfill

High End: 3.8E+1 kg/site-day over 4 days/yr from 20 sites

or 3.0E+3 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. Submission does not estimate

releases.

Air

Typical: 1.6E-1 kg/site-day over 365 days/yr from 20 sites

Worst Case: 1.6E-1 kg/site-day over 365 days/yr from 20

sites

to: air

from: Unloading Liquid Raw Material from Tank Trucks

basis: EPA/OAQPS AP-42 Loading Model. Note that the VP

for this PMN (168 torr) falls outside of the recommended

vapor pressure range of 0.001-35 torr for this model.

Air

Typical: 1.6E-1 kg/site-day over 365 days/yr from 20 sites

Worst Case: 1.6E-1 kg/site-day over 365 days/yr from 20

sites

to: air

from: Loading Liquid Product into Tank Trucks

basis: EPA/OAQPS AP-42 Loading Model.

RELEASE TOTAL

7.7E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 60

Basis:

Inhalation:

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Exposure to Vapor (Class II)

Typical: 7.6E+1 mg/day over 250 days/yr

Worst Case: 2.3E+3 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 60

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT Mass Balance Model. Note that the VP for this

PMN (168 torr) falls outside of the recommended vapor

pressure range of 0.001-35 torr for this model. This

exposure is presented as a conservative estimate.

NOTE: The respirator class is: II. Gas/vapor (all

substances in the gas form).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 60

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0557

Number of Sites/ Location: 

 

Process Description: Rubber tire feedstock added to

reactor --> Reactor is heated to 750 degrees and F -->

Gas vapors are pulled from the reactor under vacuum -->

Vapors are condensed in two streams (heavy oild and light

oil) --> The heavy and liight oils are stored in separate

2000-5000 gallon tanks --> PMN (light oil, 100%) is

pumped into 5000 gal tanker trucks (submission).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water or Incineration or Landfill

High End: 4.5E-1 kg/site-day over 365 days/yr from 20

sites

or 3.3E+3 kg/yr

to: uncertain

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from: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. The submission does not discuss

releases.

Air

Typical: 1.6E-1 kg/site-day over 365 days/yr from 20 sites

Worst Case: 1.6E-1 kg/site-day over 365 days/yr from 20

sites

to: air

from: Unloading Liquid Raw Material from Tank Trucks

basis: EPA/OAQPS AP-42 Loading Model.

RELEASE TOTAL

5.6E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 60

Basis: The submission does not provide worker estimates.

CEB assumes a minimum of 3 workers/site.

Inhalation:

Exposure to Vapor (Class II)

Typical: 7.6E+1 mg/day over 250 days/yr

Worst Case: 2.3E+3 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 60

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT Mass Balance Model.

NOTE: The respirator class is: II. Gas/vapor (all

substances in the gas form).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 1.00% concentration

High End: 1.8E+1 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 60

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

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